Quick Reference Guide
Online Courier: Disclosure Requirements for Remittance Transfer Rule
As of October 28, 2013, the Consumer Financial Protection Bureau (CFPB) implemented the Remittance Rule
Implementation (Subpart B of Regulation E - the “Remittance Transfer Rule”). The details of the ruling can be
found on the following website: http://www.consumerfinance.gov/policy-compliance/rulemaking/finalrules/electronic-fund-transfers-regulation-e/. The Remittance Transfer Rule requires that consumers sending
overseas wire transfers receive prepayment disclosures and receipts setting forth certain information with
respect to the transaction. This document shows you how SunTrust supports the delivery of the required
prepayment disclosures and the receipts to a financial institution’s consumer clients wishing to send wire
transfers overseas, and it may also be used by agents initiating international wire transfers from consumer
accounts through Online Treasury Manager or Online Foreign Exchange.
The SunTrust Online Courier® Remittance Transfer process is a stand-alone reporting service that is not
connected to Online Treasury Manager or Online Foreign Exchange. This process is used exclusively for
generating disclosures and receipts; Online Courier does not generate the actual wire transfer. Consumer
international wires will still need to be initiated separately.
Generating Disclosures and Receipts
IMPORTANT NOTE for first time financial
institution users: Before generating disclosures
and receipts that comply with Reg E
requirements, the financial institution’s
security administrator must enter their related
Financial Institution Error Resolution and
handling, and originating bank fees as
applicable. Refer to Exhibit 1 for sample text.
This one-time setup step can be accomplished
by clicking the Wire Disclosure Admin link
under the Payments & Transfers tab. Financial
institutions are not permitted to use SunTrust
Bank disclosure text, and must uncheck the Use
Bank Defaults box. These disclosures are
required to include information specific to the error resolution contact information of their financial institution.
Agents will use the SunTrust Bank disclosure text. When this is completed, click the Save button.
To Generate Disclosures and Receipts
1. Under the Payments and Transfers tab, select the Wire Disclosures link. The Wire Disclosures page
appears.
a. If you would like to manually enter wire details to generate a disclosure, click the Manual button and
continue to Step 2.
b. If you would like to import wire instructions to generate a disclosure, click the Import button and
navigate to the location where your Microsoft Excel® or .txt file containing the disclosure information,
After the successful import screen appears, proceed to Step 4.
Note: For import file specifications, refer to Exhibit 3.
2. Complete the Wire Disclosure form based on the information provided by the consumer debit party. Refer to
Exhibit 2 for further explanation of the fields on this form.
3. After completing the required information as well as any optional fields, check the Do you accept the
addendum to the Terms and Conditions? box at the bottom of the page.
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Note: The addendum is available on the Online Courier User Reference Materials page, accessible within the
service from the Product Info link.
4. Click the Review button. The Pre-Payment Disclosure and Receipt will display in English and Spanish for
your final review.
5. If you need to make changes, click the Edit button. Otherwise, click the Submit button. A confirmation
message will display, and the disclosures will be sent to the email address on your Online Courier Profile.
You can print disclosures by clicking the Print button.
Note: Security Administrators have the option of automatically receiving copies of all emails to the address in
their profile if the Wire Disclosures box in the profile is checked.
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Important Notes
A wire should not be released by a financial institution* or agent through Online Treasury Manager or Online
Foreign Exchange before the 30 minute waiting period, and the consumer debit party has the right to cancel the
payment within that 30 minute waiting period.
When a consumer debit party (“sender”) furnishes an incorrect account number or bank identifier, there are five
conditions that must be met in order for a remittance transfer provider to avoid liability. First, the remittance
transfer provider must demonstrate that the sender furnished an incorrect account number or bank identifier.
Second, where the error is an incorrect identifier for the receiving institution, the remittance transfer provider
must use “reasonably available means” such as commercially available databases or directories to verify the
bank identifier, if it is feasible to do so. Third, the remittance transfer provider must give notice before the
sender authorizes the remittance that an incorrect account number or bank identifier may cause the funds to be
misdirected and the sender could lose the funds; the rule does not specify a notice other than requiring it to be
clear and conspicuous, but the notice can be given orally if the prepayment disclosure is provided orally. Fourth,
the remittance transfer provider must demonstrate that the funds were deposited to the wrong account.**
Finally, the remittance transfer provider must use reasonable means to attempt to recover the funds of the
sender.**
Where indicated, fees, amounts, taxes, and rates will be estimated depending on the currency and the country
where the funds are being sent. Recipients may receive less than the transfer amount due to fees charged by
recipient’s bank and foreign taxes.
If a Foreign Exchange contract was purchased (through any channel) and the consumer debit party cancels the
payment within the 30 minute waiting period, the financial institution or agent which obtained the contract
must immediately contact the SunTrust Foreign Exchange Desk by calling 800.494.9782. Any losses associated
with Foreign Exchange contracts that are cancelled will be charged directly to the financial institution or agent
(please refer to the addendum for definition) and will not be incurred by SunTrust.
Online Courier provides three years of wire disclosure record retention, available in the Resend queue at the
company or user levels.
*Financial institution as defined in the Financial Institution Remittance Transfer Addendum.
** SunTrust may be able to provide assistance with researching this condition.
Exhibit 1: Disclosure Party and User Interface Field Definitions
Party/Field
Definition
Bank to Bank Information
Bank to Bank information provided by the consumer debit party
Contract Field
Checkbox to allow for the entry of a foreign exchange contract number and
associated rate. Contracts apply to Online Foreign Exchange transactions and
transactions with the Foreign Exchange Desk
Debit Party
Consumer who holds an account at the financial institution as defined in the
Financial Institution Remittance Transfer Addendum
Debiting Account Field
Consumer debit party’s account number
Disclosure/Receipt Currency
Display
Changes the currency display for specific areas of the disclosure
Exchange Rates
Exchange rates for selected currency
Financial Institution
Financial institution as defined in the Financial Institution Remittance Addendum
Foreign Country Field
Country where recipient/beneficiary account field is held
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Originator to Recipient
Information
Originator to recipient/beneficiary information as provided by the consumer debit
party
Originating Bank Fees Field
Optional fees that may be added/removed by the financial institution to pass on
to the consumer debit party
Process Currency Field
Currency that consumer debit party wants to send
Recipient/Beneficiary
The party who will receive the funds per the instructions provided by the
consumer debit party
Recipient/Beneficiary Bank
The recipient’s Bank information (SWIFT address)
Disclosure Text: Financial
Institution Error Resolution
Information. This information
must be entered into Online
Courier by the financial
institution’s security
administrator.
SAMPLE ONLY: You have the right to dispute errors in your transactions. If you
think there is an error, contact us within 180 days at 800.XXX.XXXX or
www.financialinstitution.com. You can also contact us for a written explanation
of your rights. You can cancel for a full refund within 30 minutes of payment,
unless the funds have been picked up or deposited. For questions or complaints
about Your Bank, contact:
Georgia Department of Banking and Finance
2990 Brandywine Road, Suite 200
Atlanta, Georgia 30341-5565
(888) 986-1633 or http://dbf.georgia.gov/
Consumer Financial Protection Bureau
855.411.2372
855.729.2372 (TTY/TDD) or www.consumerfinance.gov
Exhibit 2: Definitions Related to Prepayment Disclosure and Receipts
Transfer Amount is the amount in USD (or
other currency if box is checked for
Disclosure Receipt Currency Display) that is
being requested to be sent by the consumer
debit party.
Transfer Fees are the amount in USD that
is charged to the consumer debit party by
the financial institution where the wire is
originated.
Other Fees and Other Taxes are the amounts in
USD or other currency that are charged by the
correspondent banks.
Exchange Rate is the foreign currency rate
applied to the transfer. If entered, the contract
number will display next to the rate.
Date of Availability is seven business days after the
expected value date; funds may be available
sooner. Value Date is two business days after the
Send Date, excluding applicable holidays.
Time is the time that the disclosure was generated
and provided to the consumer debit party. The
wire should not be released through Online
Treasury Manager or Online Foreign Exchange
before the 30 minute waiting period and the
consumer has the right to cancel the payment
within that period.
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Exhibit 3: File Format for Importing Wire Disclosures
Field
Name
Content
Field Requirement (For Wire
Instructions)
Field Requirement/Notes (for Wire
Disclosures)
1
Ordering Customer
(Name)
Maximum
35
characters
Conditional: required if
ordering customer information
is included in wire
Required
Note: Maps to ‘Debit Party Name’ in
Wire Disclosure
2
Ordering Customer
Address Line 1
Maximum
35
characters
Conditional: required if
ordering customer information
is included in wire
Optional
Note: Maps to Line 1 of ‘Debit Party
Address’ in Wire Disclosure
3
Ordering Customer
Address Line 2
Maximum
35
characters
Conditional: required if
ordering customer information
is included in wire
Optional
Note: Maps to Line 2 of ‘Debit Party
Address’ in Wire Disclosure
4
Ordering Customer
Address Line 3
Maximum
35
characters
Optional
Optional
Note: Maps to Line 3 of ‘Debit Party
Address’ in Wire Disclosure
5
Recipient Name
Maximum
34
characters
Required
Required
Note: Maps to ‘Beneficiary Name’ in
Wire Disclosure
6
Recipient ID
Value =
Account
number of
beneficiary
Required
Required
Note: Maps to ‘Beneficiary Account’
in Wire Disclosure
7
Recipient Address
Line 1
Maximum
35
characters
Optional
Conditional: required if no value
has been provided for Beneficiary
Address Line 2 or 3
Note: Values can be provided for
any combination of ‘Beneficiary
Address Line’. Example: 1, 2, 3; 1
and 3; 2 and 3; 1 and 2
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Recipient Address
Line 2
Maximum
35
characters
Optional
Conditional : required if no value
has been provided for Beneficiary
Address Line 1 or 3
Note: Values can be provided for
any combination of ‘Beneficiary
Address Line’. Example: 1, 2, 3; 1
and 3; 2 and 3; 1 and 2
9
Recipient Address
Line 3
Maximum
35
characters
Optional
Conditional: required if no value
has been provided for Beneficiary
Address Line 1 or 2
Note: Values can be provided for
any combination of ‘Beneficiary
Address Line’. Example: 1, 2, 3; 1
and 3; 2 and 3; 1 and 2
10
Recipient Bank
Name
Maximum
34
characters
Conditional: required if
Beneficiary Bank ID is included
in wire
Required
5
11
Recipient Bank ID
Value = An
8 or 11
character
SWIFT code
Conditional: required if
Beneficiary Bank ID is included
in wire
Required
12
Recipient Bank
Address 1
Maximum
34
characters
Conditional: required if
Beneficiary Bank ID is included
in wire
Conditional: required if no value
has been provided for Beneficiary
Bank Address Line 2 or 3
Note: Values can be provided for
any combination of ‘Beneficiary
Bank Address Line’. Example: 1, 2,
3; 1 and 3; 2 and 3; 1 and 2
13
Recipient Bank
Address 2
Maximum
34
characters
Conditional: required if
Beneficiary Bank ID is included
in wire
Conditional: required if no value
has been provided for Beneficiary
Bank Address Line 2 or 3
Note: Values can be provided for
any combination of ‘Beneficiary
Bank Address Line’. Example: 1, 2,
3; 1 and 3; 2 and 3; 1 and 2
14
Recipient Bank
Address 3
Maximum
34
characters
Optional
Conditional: required if no value
has been provided for Beneficiary
Bank Address Line 2 or 3
Note: Values can be provided for
any combination of ‘Beneficiary
Bank Address Line’. Example: 1, 2,
3; 1 and 3; 2 and 3; 1 and 2
15
Intermediary Bank
Name
Maximum
34
characters
Conditional: required if
including Intermediary Bank
information in the wire, and
not including
Intermediary Bank ID Type and
ID
Optional
Note: Maps to ‘Pay Through Bank
Name’ of Wire Disclosure
16
Intermediary Bank
ID
Value = 9
digit ABA
number
OR 8 or 11character
SWIFT code
Conditional: required if
Intermediary Bank ID is
included
Optional
Note: Maps to ‘Pay Through Bank
ID’ of Wire Disclosure
17
Intermediary Bank
Address Line 1
Maximum
35
characters
Conditional: required if
including Intermediary
Bank information in the
wire, and not including
Intermediary Bank ID Type
and ID
Optional
Notes: Values can be provided for
any combination of ‘Intermediary
Bank Address Line’. Example: 1, 2,
3; 1 and 3; 2 and 3. Maps to Line 1
of ‘Pay Through Bank Address’ of
Wire Disclosure
18
Intermediary Bank
Address Line 2
Maximum
35
characters
Conditional: required if
including Intermediary
Bank information in the
wire, and not including
Intermediary Bank ID Type
and ID
Optional
Notes: Values can be provided for
any combination of ‘Intermediary
Bank Address Line’. Example: 1, 2,
3; 1 and 3; 2 and 3. Maps to Line 2
of ‘Pay Through Bank Address’ of
Wire Disclosure
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19
Intermediary Bank
Address Line 3
Maximum
35
characters
Optional
Optional
Notes: Values can be provided for
any combination of ‘Intermediary
Bank Address Line’. Example: 1, 2,
3; 1 and 3; 2 and 3. Maps to Line 3
of ‘Pay Through Bank Address’ of
Wire Disclosure
20
Details of Payment
Line 1
Maximum
34
characters
Optional
Optional
Notes: Values can be provided for
any combination of ‘Details of
Payment Line’. Example: 1, 2, 3, 4;
1 and 4; 2 and 3; 1, 2, 4. Maps to
Line 1 of ‘Originator to Recipient
Information’ of Wire Disclosure
21
Details of Payment
Line 2
Maximum
34
characters
Optional
Optional
Notes: Values can be provided for
any combination of ‘Details of
Payment Line’. Example: 1, 2, 3, 4;
1 and 4; 2 and 3; 1, 2, 4. Maps to
Line 2 of ‘Originator to Recipient
Information’ of Wire Disclosure
22
Details of Payment
Line 3
Maximum
34
characters
Optional
Optional
Notes: Values can be provided for
any combination of ‘Details of
Payment Line’. Example: 1, 2, 3, 4;
1 and 4; 2 and 3; 1, 2, 4. Maps to
Line 3 of ‘Originator to Recipient
Information’ of Wire Disclosure
23
Details of Payment
Line 4
Maximum
34
characters
Optional
Optional
Note: Values can be provided for
any combination of ‘Details of
Payment Line’. Example: 1, 2, 3, 4;
1 and 4; 2 and 3; 1, 2, 4, etc.
Note: Maps to Line 4 of ‘Originator
to Recipient Information’ of Wire
Disclosure
24
Debit Account #
Maximum
13
characters
Required
Required
Note: Maps to ‘Debiting Account’ in
Wire Disclosure
25
Debit/Credit
Amount
Numeric Maximum
13
characters
(includes
decimal)
Optional
Note: Value in this field is in the
currency indicated in ‘Debit
Account Currency’ field
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Getting Help
Click the Help link at the top right of any page.
If your User ID or Password becomes disabled,
contact your company security administrator (CSA)
about resetting your User ID and Password.
For all your other service needs, please call your
Treasury Management Client Services Specialist at
866.448.6392. Representatives are available from
8:00 a.m. - 6:00 p.m. ET Monday through Friday on
bank business days.
If you need technical assistance, please contact
SunTrust Treasury Management Technical Services at
877.785.6925. Representatives are available from
8:00 a.m. - 6:00 p.m. ET Monday through Friday on
bank business days.
SunTrust Bank, Member FDIC ©2016 SunTrust Banks, Inc. SunTrust and SunTrust Online Courier are federally registered service marks of
SunTrust Banks, Inc. Other trademarks, service marks and trade names are the property of their respective owners.
STB T&PS OLC Rev. 11/16
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